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Preservation of important historic sites, both on the U.S. Army’s Pinon Canyon Maneuver Site, and on U.S Forest Service lands along the Santa Fe Trail, were addressed in two letters the Otero County Commissioners issued to both federal agencies on Monday, April 12.
The letters were drafted after the county commissioners had detailed discussions with their County Historic Preservation Advisory Board about how to protect sites, both cultural and archeological.
The first letter, sent to the Army, raises questions on how historic ranching sites will be protected if troops move their training exercises into canyons on the 238,000-acre maneuver site. At least one group, Colorado Preservation Inc., has listed the Purgatoire River Valley as one of the state’s most endangered historic places for at least two consecutive years, primarily because PCMS surrounds important cultural and archeological sites in the river valley. Training previously has been isolated to flat lands surrounding the canyons on PCMS.
The Army has proposed changing its training regimens to simulate conditions troops are facing in the war on terrorism in Afghanistan. The county commissioners visited PCMS on March 3 to view the ranching sites that could be impacted and to hear the Army’s plans for a new “programmatic agreement” to protect and preserve those sites, some of which could be eligible for listing on the National Register of Historic Places.
The second letter was sent to the U.S. Forest Service and addresses “proposed programmatic agreements” meant to streamline processes for review of actions taken on federal lands that could possibly impact Santa Fe Trail sites – and possibly more sites eligible for listing on the National Register.
Critical issues are raised in each letter about how the federal agencies will act to protect important sites, and how they will be held accountable for their actions.
The letter to the Army raises 10 concerns, the first being whether the ranches where training is proposed will be re-evaluated before training begins to insure all information is correct and sites are completely protected.
The Army has not stated publicly how many historic ranching sites could be impacted by its new training practices. Five sites are mentioned in the commissioners’ letter.
Among the other questions the commissioners raised were:
• Will archeological sites near the affected ranches also be protected?
• Will cultural resource personnel be stationed at PCMS and at the historic ranch site during training operations to monitor them?
• Will a group of five National Register eligible ranches on PCMS be wrapped into one programmatic agreement to streamline the review process required by the National Environmental Policy Act, instead of reviewing the ranches’ eligibility individually?
• Will the commissioners get to comment on the continual use and repair of those historic ranches and how training impacts them under new the programmatic agreement meant to streamline the NEPA review process (because training impacts could vary from site to site)?
• Will the programmatic agreement developed with the Army have a compliance schedule with deadlines and consequences clearly delineated?
• Will the types of activities that are covered by the programmatic agreement be clearly defined?
• Will activities like prescribed burns be covered by the new agreement and how will “Burned Area Emergency Rehabilitation” activities be handled?
• Will the view shed and cultural landscape outside of PCMS be considered in the Army’s plans for impacting sites?
• What are the consequences for failure to submit on time an Annual Report of Historic Properties Management Activities?
The commissioners also want to know what the next steps will be for the Army, whether additional meetings will be scheduled, and whether the new programmatic agreement will be distributed among consulting parties, such as officials from the surrounding counties and state historic officials. They also want to know if the Army is willing to take comments and answer questions about its plans.
Preservation of important historic sites, both on the U.S. Army’s Pinon Canyon Maneuver Site, and on U.S Forest Service lands along the Santa Fe Trail, were addressed in two letters the Otero County Commissioners issued to both federal agencies on Monday, April 12.
The letters were drafted after the county commissioners had detailed discussions with their County Historic Preservation Advisory Board about how to protect sites, both cultural and archeological.
The first letter, sent to the Army, raises questions on how historic ranching sites will be protected if troops move their training exercises into canyons on the 238,000-acre maneuver site. At least one group, Colorado Preservation Inc., has listed the Purgatoire River Valley as one of the state’s most endangered historic places for at least two consecutive years, primarily because PCMS surrounds important cultural and archeological sites in the river valley. Training previously has been isolated to flat lands surrounding the canyons on PCMS.
The Army has proposed changing its training regimens to simulate conditions troops are facing in the war on terrorism in Afghanistan. The county commissioners visited PCMS on March 3 to view the ranching sites that could be impacted and to hear the Army’s plans for a new “programmatic agreement” to protect and preserve those sites, some of which could be eligible for listing on the National Register of Historic Places.
The second letter was sent to the U.S. Forest Service and addresses “proposed programmatic agreements” meant to streamline processes for review of actions taken on federal lands that could possibly impact Santa Fe Trail sites – and possibly more sites eligible for listing on the National Register.
Critical issues are raised in each letter about how the federal agencies will act to protect important sites, and how they will be held accountable for their actions.
The letter to the Army raises 10 concerns, the first being whether the ranches where training is proposed will be re-evaluated before training begins to insure all information is correct and sites are completely protected.
The Army has not stated publicly how many historic ranching sites could be impacted by its new training practices. Five sites are mentioned in the commissioners’ letter.
Among the other questions the commissioners raised were:
• Will archeological sites near the affected ranches also be protected?
• Will cultural resource personnel be stationed at PCMS and at the historic ranch site during training operations to monitor them?
• Will a group of five National Register eligible ranches on PCMS be wrapped into one programmatic agreement to streamline the review process required by the National Environmental Policy Act, instead of reviewing the ranches’ eligibility individually?
• Will the commissioners get to comment on the continual use and repair of those historic ranches and how training impacts them under new the programmatic agreement meant to streamline the NEPA review process (because training impacts could vary from site to site)?
• Will the programmatic agreement developed with the Army have a compliance schedule with deadlines and consequences clearly delineated?
• Will the types of activities that are covered by the programmatic agreement be clearly defined?
• Will activities like prescribed burns be covered by the new agreement and how will “Burned Area Emergency Rehabilitation” activities be handled?
• Will the view shed and cultural landscape outside of PCMS be considered in the Army’s plans for impacting sites?
• What are the consequences for failure to submit on time an Annual Report of Historic Properties Management Activities?
The commissioners also want to know what the next steps will be for the Army, whether additional meetings will be scheduled, and whether the new programmatic agreement will be distributed among consulting parties, such as officials from the surrounding counties and state historic officials. They also want to know if the Army is willing to take comments and answer questions about its plans.
Forest Service also addressed
The county commissioners also addressed a proposed programmatic agreement with the U.S.D.A. Forest Service Rocky Mountain Region office in Fort Collins. The agreement also is meant to streamline consulting processes affected parties like cities and counties have when projects are proposed. In this case, it would be on the Comanche National Grasslands.
The commissioners noted they are pleased the Forest Service will submit an annual report to the State Historic Preservation Office if proposed projects are found to negatively impact important historic sites. And the agreement “clearly defines the steps which the SHPO will take if a specific forest does not meet that deadline, including removing the forest from the programmatic agreement.” The commissioners see this provision as an important component for enforcement upon individual forests, without penalizing other forests in the Rocky Mountain Region.
But then the letter raises serious concerns about processes the programmatic agreement might not address.
“The extensive intermingling of federal and private ownership within the Comanche National Grasslands makes it imperative that the forest recognize and understand the indirect impacts on historic resources on private lands, as well as the Santa Fe Trail Historic and Scenic Byway, which is a key element of heritage tourism efforts in Southeast Colorado.”
The commissioners noted that “multiple property National Register of Historic Places have been made for the Santa Fe Trail in the states of Missouri, Kansas, Oklahoma and New Mexico.” But no such multiple property listing has been prepared for Colorado, despite the fact that Bent’s Old Fort was a primary destination for travel on the Mountain Branch of the trail and “it is probable that there are sites eligible for the National Register.
“We request that the Forest Service be mindful of the inconsistency concerning eligibility of Santa Fe Trail sites within Colorado and consider both the direct and indirect impacts, including those to the view shed, when implementing the programmatic agreement on the Comanche National Grasslands,” the commissioners wrote.
They explained that Colorado Preservation Inc. is currently conducting a large survey of historic resources in southern Otero County. It is expected to be completed by next year.
“Preliminary information indicates that a number of National Register eligible sites will be identified. It is imperative that the Forest Service consider on-going efforts to identify and document historic resources in Southeastern Colorado and be pro-active in continually reviewing eligibility records through the Colorado Office of Archeology and Historic Preservation.”
The letter was copied also to Shina Duvall at the Colorado State Historic Preservation Office. No comment was made when a response would come from the regional forester’s office.
